United States
Environmental Protection
Agency
Off ice of
Solid Waste and
Emergency Response
x> EPA
DIRECTIVE NUMBER: 9355.0-36
TITLE: FY92 Themes for Regional (Coordination to
Support Continuous Improvements of Superfund's
Remedial Program
APPROVAL DATE: 12/11/91
EFFECTIVE DATE: 12/11/91
ORIGINATING OFFICE: OERR
Q FINAL
D DRAFT
LEVEL OF DRAFT
L~] A — Signed by AA or DAA
Q B — Signed by Office Director
n C — Review & Comment
REFERENCE (other documents):
OSWER OS WE Ft OSWER
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OSWER Directive Initiation ReQuest
1. Ortat"ator InformaUon
Name 01 ContAcz PInOft Mall COde iO~~ . r eecnen. COd.
Bet ti VanEpps I 5201G I 260-9760
J. "Ue FY92 Themes for Regional Coordination to Support Continuous Improvements
of Superf'lIDd' s Remedial Program
4. Su",,,,.,.., 01 :"8CUlte \,nc::uc:e o"el 11alerT'leni 01 :)ur=es.,
This memorandum outlines the FY92 themes for regional coordination to support
continuous improvements of Superf'lIDd I s remedial program.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
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DEC I I 199f
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SOLIC) W~S':'= AND ='.'=~r::;E;o..cv RESPONSE,
I
OSWER Directive '9"355.0-36
MEMORANDUM
TO:
FY 92 Themes for Regional Coordination to Support
continuous Improvements of supe~f d~s emedial
f Program, , I
/ ~~~~eL~fLo~~~~~n~~'a~~r~;;~~ia ~ponse
/~ruce M. Diamond, Director~~~ JI, ~
J Office of Waste Programs Enforce~t~~
Directors, Waste Management Division, Regions I,
IV, V, VII, VIII '
Director, Emergency and Remedial Response
Division, Region II
Directors, Hazardous Waste Management Division,
Reqions III, VI, IX
Director, Hazardous Waste Division, Region X
SUBJSCT:
PROM:
Purpos.: This memorandum outlines the FY 92 themes for
regional coordination to support continuous improvements of
Superfund's remedial program. Themes represent critical program
areas that require special emphasis by Regional management,
staff; and Reqional Coordinators. This effort will improve the
efficiency'and quality of the Supe~fund program which furthers
our commitment to Total Quality Management. Regional
Coordinators will promote guidance awareness and national
consistency. '
BackgroUD41 Themes address issues that either challenge
Superfund or represent new policies that often require fine
tuning for successful implementation. Regional Coordinators
consult policy writers, the" Regions, and each other to address
issues raised by Regional staff. They suggest ideas and creat l...e
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sol~tions employed by other Regions. Critical issues (especially
themes) and ideas that are communicated by your staff and
management to Regional Coordinators are passed along to policy
writers to improve our guidance and to promote national
consistency. This cooperative communication network between
Regions and Headquarters ensures that guidance and support is
focused on Regional program priorities.
Implementation: Implementation of the themes will require
commitments from Regional management and staff, with support fro~
Regional Coordinators, to identify and resolve issues before they
may impede the remedial process. Flagging issues as early as
possi~le in the remedial process offers more time to develop
solutions and to prepare for negotiations. Each theme will
require a varying degree of emphasis from the Regional
Coordinators. The themes are listed in order of time dedicated
to accomplish them. These themes include:
1)
Bnsure cleanup standards and risk manaqementdecisions
are est~lished and clearly documented.
Settlements and RD/RAs are expedited when cleanup
standards and risk management decisions are resolved
early (i.e., before the RI/FS is completed) and
sufficiently documented. In FY 92, Regional
Coordinators will focus on identifying and screening
alternatives and documenting cleanup levels. Regional
Coordinators will assist RPMs with clearly documenting
cleanup standards and risk management decisions in the
FS, proposed plan, and ROD. Regional Coordinators will
also raise to OGC cleanup goals which states are
claiming are ARARs but the Regions do not agree.
2)
Bxplore ways to streamline the remedial process. For
FY 92, streamlining the remedy selection process is a
major program priority for which several projects are
underway. Regional Coordinators will work with the
Regions to identify ways to expedite response actions -
including the use of removal actions and removal
enforcement authorities. Also, They will work with
Regions to identify types of sites and creative ideas
for policy development on screening alternatives and
standardizing or improving national consistency of
remedy selection. For example, recent guidance for
municipal landfills and PCB sites suggests a focused
RI, FS, and risk assessment. Regional Coordinators
will also work with the Regions to expedite response
actions and move sites to deletion.
".
3)
utili.. "Bnforcement Smart" techniques to expedite
. .settlements. Regional Coordinators will work with
Regions to help resolve issues to implement current
guidance in sending special notice letters out at ROD
signature or shortly after. They will elevate issues
to their ~anagement that affect. reaching a settlement
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within the moratorium period. For de minimis
settlements, Regional Coordinators will work with the
Regions particularly to identify and achieve de minimis
settlements prior to ROD signature (a strategy to do
this is being completed). They will assist Regions in
identifying ways to accelerate.RD during most
settlements so that RD is routinely initiated by the
time the consent decree is lodged (guidance to
implement this goal will be issued). Also, they will
encourage timely negotiation completions and RD starts
by using the Fund or issuing a UAO if a settlement is "
not reached within a reasonable time.
4)
Emphasize PRP compliance monitoring and oversight.
~egional Coordinators will work with RPMs.to assure
that compliance monitoring during the RI/FS and RD/RA
is being conducted effectively. Tracking systems and
definitions are under development. Once completed,
Regional Coordinators will assist in identifying and
elevating compliance issues. They will also work with
policy staff and the Regions to identify areas where
. guidance is needed to develop enforceable documents..
Regional Coordinators will also work with Regions on
deciding when. to enforce and assuring that
documentation of decisions to enforce or not to enforce
occurs.
5)
Ensure that appropriate strategies for ground-water
remedies are established and clearly documented.
Superfund's policies for ground-water restoration are
evolving. Regional Coordinators are constantly updated
. and informed of any new issues or changes. They will
work with your staff to ensure that technical concerns,
settlement issues, and contingencies for ground-water
restoration are identified early and clearly
documented.
6)
strive for early identification and resolution of state
issues to accelerate the remedial pipeline. In FY 91,
state and municipality issues were major causes for
remedial delays. State issues that often require early
identification and resolution to prevent delays may
include: ARARs and waivers; states declining
assurances; state role issues, poor document quality,
and lengthy turn around time for document review.
Regional Coordinators will work with RPMs to identify
and elevate potential state issues to Regional and
Headquarters' management early in the process. The
mechanism for raising State issues is being developej
. as a 30-day implementation project. For municipall~1'
issues, Regional Coordinators will update their
management on Regional concerns and let the Regions
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7)
know current Headquarters' .directions.
Promote routine consideration of innovative
technologies in the remedy selection process. OSWER
Directive 9380.0-17 emphasizes Headquarters/AA support
for the development and use of innovative treatment
technologies in the remedial program. Early
understanding of innovative alternatives and the
commitment to their routine consideration in the remedy
selection process are essential to selecting more
effective and less costly remedies while not delaying I,
the remedy selection process. Regional Coordinators
will encourage Regional, staff to consider innovative
technologies at scoping and while the RI. is underway.
The Technology Innovation Office will update the
Regional Coordinators on new guidance and technology
issues.
Regional Coordinators will assist you with the development
of options to address these themes and other critical issues.
Regional Coordinators often identify potential obstacles and
suggest appropriate guidance when they meet with RPMs to discuss
site scoping, draft RI/FSs, and during their review of draft
proposed plans and during negotiations. We stro~gly encourage
Regional staff to involve Regional Coordinators at scoping and to
provide them the opportunity to comment on draft proposed plans
as well as draft RODs, ESDs, ROD amendments, and pre-referral
negotiation documents. Regional Coordinators will also be
available to assist the Regions with issues relating to RI/FS and
RD/RA oversight.
The FY 92 themes that address the quality and consistency of
remedial decision-making will be included in the yearly ROD
Analysis. Remedy delegation consultation requirements include
some of these themes and other important issues, such as
reviewing containment-only remedies. Regional Coordinators will
work closely with RPMs on all areas outlined in the FY 92 Remedy
Delegation Report. Furthermore, several enforcement guidance
documents are expected to be written this year which will support
the enforcement themes. Regional Coordinators may also be
available to participate in Regional TQM workgroups that support
~hese critical themes.
Together the OERR and OWPE Regional Coordinators will meet
with your staff to discuss Regional priorities for FY 92 regional
coordination. If you have any suggestions on how we can further
refine or modify the Regional Coordinator's role to better serve
your needs, please let us know. Attached is the list of Regional
Coordinators in OERR and OWPE.
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Attachment
cc:
Jerry Clifford, Director, HSCD
Sally Mansbach, Director, CED
Debbie Dietrich, Acting Director, HSED
Walt .Kovalick, Director, TIO
Larry starfield, OGC
OERR Regional Coordinators
OWPE Regional Coordinators.
Superfund Branch Chiefs, Regions I-X
Superfund Regional Counsel Branch Chiefs, Regions I-X
Superfund section Chiefs, Regions I-X
Branch Chiefs, Environmental Services Division, Regions I,
VI, VII
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REGIONAL COORDINATORS
Fund and Enforcement Lead:
Fund Lead: RifFS and ROD Design and Constn.lctlon
Region Name FTS No.. Region Name FTS No. .
1 Robin Anderson 678-8371 1 JoAnn Griffith 678-8353
2 Loren Henning (NJ) 678-8392 2 Joe CocaJis 678-8356
Shahid Mahmud (NY) 678.8372 3 Florence Blair 678-8327
3 Sharon Frey 678-8367 4 Ken Skahn 678-8355
4 Tish O'Conor 678-8370 5 Tracy Loy 678-8349
5 Andrea McLaughlin 678-8365 6 JoAnn Griffith 678-8353
Peter Feldman 678-8364 7 Ken Skahn 678-8355
6 David Cooper 678.8361 8 Barbara McDonough 678-8347
7 Tish O'Conor 678-8370 9 Steve Chang 678-8348
8 Nancy Briscoe 678-8360 10 Steve Chang 678-8348
9 David Cooper 678-8360
10 Nancy Briscoe 678-8360
Enforcement Lead: RifFS, ROD, RD/RA Negotiations
Region Name FTS No.. Region Name FTS No. .
1 Amy Legare 678-8626 5 Trish Gowland (IL. IN) 678.8622 ; ~
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2 Lance Elson (NY) 678-8621 Ernie Watkins (MI. WI) 678-8633
Wendi Thomi (NJ) 678-8627 Leslie Jones (MN. OH) 678-8631
3 Kathryn Boyle (VA, WV, PAl 678-8614 6 Filomena Chau 678-8619
Elisabeth Freed (DE. MD, PA) 678-8608 7 Jack Schad 678-8629
4 Neilima SenJCilia (FL. AL. GA, MS) 678-8630 8 Lori Boughton 678.8613
Darlene Boerlage (KY, TN, NC. SC) 678.8646 9 Rick Popino (Site Specific) 678.8628
Kun Lamber (Site Specific) 678-8624
10 Joe T eiger 678.8632
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.Commercial phone number (703) 308-8444
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